The Supreme Court has affirmed the principle of finality of judgments, emphasizing that once a decision becomes final and executory, it is immutable and unalterable. In Republic vs. Heirs of Spouses Molinyawe, the Court ruled that a Regional Trial Court (RTC) cannot exercise jurisdiction over a case involving property that was already subject to a final judgment by a co-equal court in a prior forfeiture case. This decision reinforces the importance of respecting judicial hierarchy and the conclusiveness of final judgments.

From Forfeiture to Quieting of Title: A Clash of Jurisdictions

This case stemmed from a forfeiture case (Civil Case No. 6379) filed by the Republic of the Philippines against Florentino Molinyawe and others, involving several parcels of land. Simultaneously, criminal cases for malversation (Criminal Case Nos. 2996 and 2997) were filed against Florentino Molinyawe. The forfeiture case, initiated due to the alleged illegal acquisition of properties by Florentino, resulted in a decision by the Court of First Instance (CFI) of Pasig declaring the sale of the subject properties to certain individuals null and void, and ordering their forfeiture in favor of the Republic. This decision became final and executory.

Years later, after Florentino was acquitted of malversation in the criminal cases, his heirs filed a complaint/petition (Civil Case No. 10-658) with the RTC of Makati seeking the cancellation of the lis pendens (notice of pending litigation) annotated on the titles of the subject properties and for quieting of title, arguing prescription due to the non-execution of the forfeiture decision. However, the Republic had also initiated a separate action (LRC Case No. M-5469) to annul the owner’s duplicate copies of the titles and obtain new ones in its name, which was decided in its favor. The RTC-Makati declared the owner’s duplicate copies held by the heirs null and void and directed the Register of Deeds to issue new copies to the Republic.

The legal battle intensified when the heirs, armed with the acquittal of Florentino, sought to amend their petition in the RTC, aiming to challenge the Republic’s claim over the properties. The Republic, however, argued that the RTC lacked jurisdiction to entertain the amended petition, as it effectively sought to overturn a final and executory decision of a co-equal court. The Republic asserted that only the court with jurisdiction over the main action (the forfeiture case) could order the cancellation of the lis pendens. This principle is rooted in the concept of lis pendens itself, which, as the Court in J. Casim Construction Supplies, Inc. v. Registrar of Deeds of Las Piñas, explained:

Lis pendens — which literally means pending suit — refers to the jurisdiction, power or control which a court acquires over the property involved in a suit, pending the continuance of the action, and until final judgment. Founded upon public policy and necessity, lis pendens is intended to keep the properties in litigation within the power of the court until the litigation is terminated, and to prevent the defeat of the judgment or decree by subsequent alienation. Its notice is an announcement to the whole world that a particular property is in litigation and serves as a warning that one who acquires an interest over said property does so at his own risk, or that he gambles on the result of the litigation over said property.

The Supreme Court sided with the Republic, emphasizing the significance of a final and executory judgment. The Court referred to Section 1, Rule 9 of the Rules of Court:

Section 1. Defenses and objections not pleaded.

Defenses and objections not pleaded either in a motion to dismiss or in the answer are deemed waived. However, when it appears from the pleadings or the evidence on record that the court has no jurisdiction over the subject matter, that there is another action pending between the same parties for the same cause, or that the action is barred by a prior judgment or by statute of limitations, the court shall dismiss the claim.

The Supreme Court underscored that the RTC-Makati overstepped its bounds by admitting the amended petition, which sought to undermine the final judgment in the forfeiture case. In this respect, the Supreme Court pointed out, “The RTC-Branch 57 cannot definitely alter a final and executory decision of a co-equal court by such a move. To do so would certainly defeat the clear purpose of amendments provided by the rules and amount to a grave abuse of discretion as well.” The Court stressed that the principle of immutability of judgments prevents any alteration or modification of final and executory judgments, reinforcing the stability and effectiveness of the judicial system. The finality of the decisions barred the RTC-Branch 57 from exercising jurisdiction on the case, even if the modification was only meant to correct an erroneous conclusion of fact or law.

Furthermore, the Court addressed the Court of Appeals’ observation that Florentino’s acquittal in the criminal cases rendered the forfeiture ineffective. The Supreme Court clarified that forfeiture cases are distinct from criminal proceedings and impose neither criminal nor civil liability arising from a crime. Citing Ferdinand R. Marcos, Jr. v. Republic of the Philippines, the Supreme Court emphasized that forfeiture cases are civil in nature and aim to recover unlawfully acquired properties, independent of any criminal proceedings. Executive Order No. 14 authorizes the filing of forfeiture suits that will proceed independently of any criminal proceedings.

The decision highlights the importance of respecting the jurisdiction of courts and the finality of their judgments. The Court has made it clear that judgments must attain finality to provide closure and prevent endless litigation. The immutability of final judgments ensures that the decisions of adjudicating bodies are respected and enforced, contributing to the stability and effectiveness of the legal system.

The proper venue for challenging the effects of the forfeiture would have been within the same case where the judgment was rendered, not through a separate action that attempts to collaterally attack the final judgment. Litigants cannot use subsequent events, such as an acquittal in a related criminal case, to reopen or modify a final judgment in a civil forfeiture case. The decision reinforces the idea that prescription and estoppel do not lie against the State, particularly in matters involving public interest and recovery of ill-gotten wealth. The Supreme Court further reiterated that even if new evidence surfaces or errors are discovered, final judgments generally remain binding and unalterable.

This case serves as a crucial reminder to parties involved in legal disputes to exhaust all available remedies within the prescribed timeframes. Once a judgment becomes final and executory, it is generally beyond the reach of judicial modification, and any attempt to circumvent this principle will be met with strong judicial resistance. The case underscores the need for parties to diligently pursue their legal claims and challenges within the appropriate legal framework and procedural rules.

FAQs

What was the key issue in this case?	The key issue was whether the RTC had jurisdiction to hear a case seeking to overturn or modify a final judgment of a co-equal court in a prior forfeiture case.
What is a notice of lis pendens?	A notice of lis pendens is a warning to the public that a particular property is subject to pending litigation, and anyone who acquires an interest in the property does so at their own risk.
What does “final and executory” mean?	A decision is considered final and executory when it can no longer be appealed or modified, and the court can proceed with its enforcement.
What is the principle of immutability of judgments?	The principle of immutability of judgments states that once a judgment becomes final and executory, it cannot be altered or modified, even if there are errors of fact or law.
Are forfeiture cases criminal or civil in nature?	Forfeiture cases are generally considered civil in nature, aimed at recovering unlawfully acquired properties, and are separate from criminal proceedings.
Can an acquittal in a criminal case automatically dismiss a forfeiture case?	No, an acquittal in a criminal case does not automatically dismiss a forfeiture case, as the two are distinct proceedings with different objectives.
What court has the authority to cancel a lis pendens?	The court with jurisdiction over the main action or proceeding involving the property has the authority to order the cancellation of a lis pendens.
What is grave abuse of discretion?	Grave abuse of discretion is the capricious or whimsical exercise of judgment that effectively brings the acting entity outside the exercise of its proper jurisdiction, as when the power is exercised in an arbitrary or despotic manner by reason of passion or personal hostility.

This ruling underscores the critical importance of adhering to procedural rules and respecting the finality of judicial decisions. The Supreme Court’s decision reaffirms the principle that once a judgment becomes final, it is immutable and cannot be collaterally attacked in a separate proceeding. This promotes stability in the legal system and prevents endless litigation.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: REPUBLIC OF THE PHILIPPINES, VS. THE HEIRS OF SPOUSES FLORENTINO AND PACENCIA MOLINYAWE, G.R. No. 217120, April 18, 2016